UPDATE on BMBP’s work to hold the Forest Service Accountable on Clean Water and data transparency:

BMBP has been working to ensure that the US Forest Service (USFS) submit their stream water quality data to the Oregon Department of Environmental Quality (ODEQ) in response to ODEQ’s “Call for Data”. The data call is now officially closed, but ODEQ has expressed willingness to be flexible in accepting Forest Service data past the deadline.

BMBP’s research into recent timber sales on National Forests in eastern Oregon has uncovered serious data gaps in the state’s water quality database. The Forest Service has data showing water quality violations in numerous streams on public lands. These violations are often very severe, and limiting or lethal to salmon. However, ODEQ is not able to track many of these violations as intended by regulatory processes, because the Forest Service has not been submitting data most of their data to ODEQ for many years. Without an accurate listing of which streams are violating water quality standards, it is impossiblefor state and federal agencies to work together to develop plans to restore streams or address watershed-scale issues. It also makes it very difficult for the public to be informed about or have access to accurate information regarding these issues.

As part of our efforts to pressure the Forest Service to submit their water quality data to ODEQ, we’ve written to Forest Supervisors, talked to numerous Forest Service staff and Regional representatives, and highlighted our concerns to ODEQ. For example, you can read our letter to USFS Forest Service Supervisor’s HERE. You can also read our comments to ODEQ regarding this and related issues, such as our ongoing concerns about water quality degradation due to logging on National Forests in eastern Oregon, HERE. You can review some of the streams we’ve identified with water quality issues HERE.

As a result of BMBP’s efforts, the USFS is submitting at least some of their water quality data to ODEQ. However, the USFS only agreed to submit data housed in their regional database (their “NRIS/AQS” database). Unfortunately, it will be left up to individual USFS districts whether or not to emphasize entering any current water quality data that are not already in this database. BMBP is very concerned large amounts of key data will not be entered or included. We’re particularly worried that data relating to timber sales and grazing allotments and watersheds with ESA-listed fish (such as Bull trout and Mid-Columbia steelhead) won’t be included in the Forest Service’s data submission to ODEQ.

How can people help?

You can email the Forest Service and tell them: “Please ensure that the Forest Service submit its water quality data, including data requested by Blue Mountains Biodiversity Project in their recent Freedom of Information Act request, to the Oregon Department of Environmental Quality (ODEQ) in response to ODEQ’s “Call for Data”. ODEQ has expressed flexibility in accepting Forest Service data beyond data call deadline, but it is imperative that the Forest Service submit all of their relevant water quality data as soon as possible.

BMBP submitted a Freedom of Information Act (FOIA) request for water quality data on the Deschutes, Ochoco, Umatilla, Malheur, and Wallowa-Whitman National Forests. If the USFS fails to submit key data to ODEQ, our intent was to submit some of the USFS data to ODEQ ourselves. Even though BMBP submitted FOIA requests in late April and early May, the USFS has not provided any responsive documents or data to our requests for water quality data. We are requesting that ODEQ allow reasonable flexibility of their deadline so that this important information can be included in their call for data and upcoming assessments.

What’s at stake? Streams on public lands are suffering from widespread degradation. For example, at least 1,240 miles of streams on National Forests in the Blue Mountains are listed as water quality impaired. This estimate originates from ODEQ’s water quality assessments. However, because the Forest Service has repeatedly failed to submit their stream monitoring data to ODEQ, this figure is almost certainly a severe underestimation and fails to accurately encompass the scope of the problem on public lands.

According to state regulatory practices, streams with water quality violations are assessed and may be listed on ODEQ’s “303d list” so that agencies can identify issues and develop plans to address the causes of the water quality impairments. Without an accurate listing of which streams are violating water quality standards, it is impossible for either ODEQ or the Forest Service to develop plans to restore those streams or to address watershed-scale issues.

The most common water quality violation in the Blue Mountains is excessively high stream temperature. Many streams on public lands in eastern Oregon support threatened species such as Bull trout and Mid-Columbia River steelhead that require cold, clean water. Top predators such as Bull trout play key roles in stream ecosystems. Unfortunately, Bull trout and Redband trout have already lost much of their historic habitat. Excessive fine sediments in streams are also a serious, widespread, and severely under-reported problem.

During our ongoing research on timber sales, BMBP has found approximately 46 streams streams that exceed state water quality standards– according to the USFS’s own monitoring data. Some of these streams also exceed temperature threshold for migration, spawning, or lethal limits for aquatic species such as Mid-Columbia River steelhead. Many of these streams are not listed on the ODEQ database because the USFS has not submitted the data they have to ODEQ. Yet, the USFS often cites the absence of streams on the 303d list as part of their rationale for why logging adjacent to some of these same streams will not have significant impacts on water quality– even though their own data reflects stream temperature violations that would almost certainly place these streams on the 303d list. This is likely the tip of the iceberg. It is very likely that the problem is much more widespread, beyond the streams we had time to investigate.

We are especially concerned that the USFS continues to log vast tracks of public forests, including within streamside corridors (aka “Riparian Habitat Conservation Areas”) without adequate oversight, analysis, or adaptive management. In addition, stream temperature warming and de-watering of streams due to climate change are exacerbating the ecological degradation and loss of habitat caused by logging and livestock grazing.

In order for the state and agencies to develop plans to address widespread water quality violations, it is essential that they understand which streams are impaired, and the extent of water quality violations across the state.

Thank you! For the Streams and Wildlands,

Paula Hood, Co-Director

Blue Mountains Biodiversity Project

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